EPA’s Sleight of Hand on Cellulosic Fuel Rule Change

A few years ago, I wrote a post about the US Environmental Protection Agency’s (EPA) attempt to mandate a non-existent fuel into existence, and then fine refiners for not buying this fuel. That post was called “Why I Don’t Ride a Unicorn to Work“, and was designed to call attention to federal biofuel mandates that weren’t grounded in reality.

But what if I call a rhinoceros a unicorn? Does that mean unicorns then exist?

This week we have a guest post from Todd “Ike” Kiefer, who argues that this is effectively what the EPA has done. By declaring that the definition of cellulosic biofuels is ambiguous, the EPA has signaled that non-cellulosic feedstocks can qualify for full cellulosic tax treatment. Mr. Kiefer explains.

Previously Mr. Kiefer wrote an article highly critical of the Navy’s efforts promote biofuels in a periodical that is sent to Congress and top military leaders. The article was entitled Energy Insecurity: The False Promise of Liquid Biofuels (discussed here). His biography can be found at the end of the article.

EPA’s Sleight of Hand on Cellulosic Fuel Rule Change

by

Todd “Ike” Kiefer

The US Environmental Protection Agency is so desperate to begin counting commercial quantities of cellulosic biofuels that it has quietly rescinded the strict requirement that cellulosic fuels be made from cellulosic feedstock. This Orwellian move is revealed in their recently published new Renewable Fuel Standard (RFS) Final Rule. The new rule, just published in July, amazingly declares that “EPA considers the statutory definition of cellulosic biofuel to be ambiguous,” and that it believes Congress intended that cellulosic fuels can be made from non-cellulosic materials. Many references specifying “cellulosic biomass” for feedstock requirements have been removed from renewable fuel pathways K, L, M, and N for cellulosic ethanol, diesel, gasoline, and naphtha, even though these will all continue to qualify for full cellulosic biofuel Renewable Identification Numbers (RIN) that subsidize each gallon of production.

Under the new rule, biofuels generated from mixed feedstock will be allowed to claim 100% cellulosic RINs as long as their feedstock is “predominantly cellulosic,” which is defined as 75% or greater. Of course, this creates a huge new validation challenge for an agency which has already been censured by Congress for proving itself incapable of policing the existing RIN system from fraud. To make it easier for landfills, EPA has waved their magic wand and declared all landfill biogas to be 90% cellulosic in origin (regardless off the actual composition of the municipal solid waste feedstock and despite the testimony of many experts) and therefore eligible for full cellulosic RINs.

Biofuel producers are already exploiting the new rules in calling their mixed feedstock fuels “cellulosic” without having to validate what cellulosic portions, if any, are actually ending up in the product fuel. On its biofuel-tracking website, the EPA suddenly reported 3.5 million gallons of cellulosic biofuel in August , more than 7 times the production recorded over the preceding 42 months. This is coincidentally the month following the EPA’s cellulosic rule change, and well before POET’s Project Liberty biorefinery commenced production in September. Previous months had never registered more than a few thousand gallons and the preceding May and June both recorded zero production. The best explanation for the sudden surge is a change in the rules, not a change in the product.

A case worth considering is Quad County Corn Processors in Iowa where a bolt-on secondary bio refinery has been added to the primary conventional corn ethanol biorefinery. In the primary refinery, corn starch is extracted from the corn kernels and then fermented and distilled in the conventional process. In the secondary refinery, the feedstock is the previously discarded corn kernel husks themselves, whose outer shell is “corn bran” composed largely of hemicellulose.

This firm claims to be the first in Iowa to be producing commercial cellulosic ethanol, somehow beating out well-funded giants like POET and DuPont and Abengoa. A clue to the likely truth is in their disclosure that their new process has also increased corn oil production by 300 percent and produces cattle feed byproducts with 40% more protein. While the cellulosic corn kernel husk contains no oils or proteins, its internal starchy contents and germ do. Rather than converting the difficult cellulosic inputs into alcohol, it is much more likely that they are converting residual corn starch and germ clinging to the inside of the kernels into ethanol and corn oil and protein, and that the cellulosic kernel fiber itself is passing through largely unconverted. This theory also fits the volume of production, which only added 2 million gallons per year of ethanol to the 35 million produced from corn starch in the primary process.

Without on-site chemist inspectors to measure the mass balance of the cellulosic inputs and outputs, there is no way to assure that any fraction of Quad County’s product is truly cellulosic. Nevertheless, the new EPA rule will grant them full cellulosic RINs for their product until proven otherwise. And because the EPA has been embarrassed year after year for its unfulfilled predictions of millions of gallons of cellulosic ethanol production that have not materialized, it now has every incentive to let producers cheat.

The RFS program has also been found to be undermining its own stated goals. A recent scientific roundtable hosted by the National Academy of Sciences documents how biofuels in the US have actually increased greenhouse gas emissions and are also increasing polluting emissions compared to use of straight petroleum fuels. EPA’s own internal analysis has found that its massive RFS biofuel program has so far increased GHG emissions by 21-33% over combustion of straight gasoline motor fuel, and that it is killing up to 245 more Americans each year with increased polluting emissions of ozone and carbon particulates. Furthermore, the US Department of Energy documents on a quarterly basis that corn ethanol and soy biodiesel, even after years of multi-billion-dollar-per-year subsidies, are still far more expensive than petroleum gasoline and diesel when correctly compared on an equal-energy basis.

As of April 2014, E85 ethanol was $1.17 more per gallon than gasoline, and B100 biodiesel was $0.61 more per gallon than diesel when corrected for the reduced energy content and MPG of biofuels. And a large fraction of the inputs for so-called “renewable” fuels are non-renewable fossil fuels. Much of the megatonnage of ammonia fertilizer and herbicide and pesticide (made from fossil fuel natural gas and petroleum feedstock) used to cultivate the 129 million tons of corn used exclusively for US ethanol production (Russia’s entire annual grain crop is only 85 tons) ends up in the Gulf of Mexico perpetuating the hypoxic algae-bloom dead zone that is currently the size of Connecticut. This is like a perpetual, sea-life devastating oil spill that never goes away, and that presents a growing threat to humans with red-tide algae toxins like the microcystin that recently closed Toledo’s drinking water system.

Unfortunately, the EPA, which was created to protect the nation’s land, water, and air from pollution, has become a politicized propaganda instrument for the administration’s biofuels agenda, and is intent on pushing an RFS policy that is undermining its institutional mandates in addition to harming Americans more directly. It doesn’t get much more surreal and sinister than a federal government agency redefining black as white so they can pour more taxpayer money into a program that is increasing the death rate of their own citizens while increasing pollution and greenhouse gas emissions, and subsidizing the import of foreign sugar cane ethanol while unused US gasoline is exported.

Biography

Todd “Ike” Kiefer graduated from Annapolis in 1988 with an undergraduate degree in physics, and then earned master’s degrees in strategy and military history at the Army Command and General Staff College in Fort Leavenworth KS. He retired as a Captain after a 25-year military career as Naval aviator and electronic warfare expert (EA-6B Prowler pilot). He has been deployed eight times to the Middle East and Southwest Asia, and served twenty-two months on the ground in Iraq. He commanded Al Asad Air Base in Al Anbar Province Iraq, and spent three years as Pentagon strategic planner on Joint Staff. His most recent assignment was three years as CJCS Chair and faculty instructor of strategy, leadership, and warfighting at the US Air Force Air War College in Montgomery AL.

The guest post needs a lot of vetting. It’s written as emotional hit piece, like a military attack to crush opponents. If what was written were completely honest and accurate depiction of biofuel industry, well they’re not that many fools walking among us. The redefinition, doesn’t report like a shyster attempt to puff up production. Biogas from landfill should not have to prove energy source. Let’s get real. The Quad County cellulosic process had to go through a rigorous EPA certification for the process claims. The process utilizes corn sheath material pulling the material out of DDG. It’s good to utilize the material for high value energy product as within DDG it’s not. Better to feed cattle local hay than to ship this component. The oil resides in germ which is softened and deconstructed per loss of cellulose thus freeing up more oil. A good thing as the feed now improved for chickens, pigs, as well as cattle. If your interested in health benefit the Chicago study would be of interest. http://cleartheairchicago.com/2014/09/02/new-study-e15-reduce-smog-cancer-risk/
Also, recent discovery of micro particles of diesel blend agent is apparently awful. It was introduced for conformance of clean diesel regs. One benefit of the E85 Cummings high torque engine was greatly reducing particulates including miro particles. The comparison cost of E85 must be per retail sales as the wholesale cost of E85 is excellent. Refer to the St. Louis study that claims the petrol supply regularly marks up E85 per 2x profit margins as compared to their fuels. The proposed explanation was a marketing ploy to make petrol look better per overpriced competitor. Also, petrol is in full swing to diss ethanol blends as the reverse marketing pushes more consumers to umber profitable lead free sales. Higher blends of ethanol are attractive for health reasons as they displace the nastiest component of gasoline. The component most unhealthy. The environmental math for ethanol keeps on climbing per the science of soil microbiology, recent improvements in fertilizer to prevent emissions, low till practices, better ethanol processes, efficient distribution plant to retail, genetics for seed and plant growth with ethanol enhancement qualities. A whole ball of cellulosic improvements within the supply pipe as well. Besides ethanol makes gasoline a better, healthier product. It conserves the limited resource. All good things. Exporting oil products an issue petrol is fighting to accomplish without restrictions per maximizing utilization of efficient process plants. We want to increase exports. Also, the California low carbon fuel standard that accepts sugar cane ethanol is target number one for U.S. corn, sugar beet, and sorghum ethanol. The industry is attempting to prove land use calculations are inaccurate. Also, the introduction of bio digester greatly improve carbon rating. They appear confident of meeting requirements.

I checked, Quad country was awarded D3 RIN certification 10/07/14 and certified their Quality Assurance Program 10/10. To receive D3 cellulosic rating the biofuel must achieve 60% reduction in low carbon GHG emissions. A small group of process people at the plant invented the technology. They have some ingenious people working there. The process tied to lower viscosity of Enogen corn. This corn is hybrid tweaked to ethanol amylase enzyme growth. A Michigan State development, originally. The corn replaces the more expensive artificial enzyme and makes the whole ethanol process more efficient. Farmers paid a premium to grow small acres of the stuff and it’s sold separate. They only need a fraction of feedstock to be this variety. Quad county says the process is easy to adapt to current corn ethanol plants. It’s a no brainer decision. No extra feed stock required, just a loss in the low grade portion of DDG. This is a 2 billion gallon development per current production rates.

Good for you for doing some research. However, your results should concern you rather than comfort you.

First you need to understand the difference between starch and cellulose. Both are composed of sugar molecule building blocks, but how they are joined together makes all the difference. Starch is a non-structural powder or paste where the sugar molecules are joined by weak alpha-glycosidic hydrogen bonds that are easily broken. Cellulose, on the other hand, is a very tough, long-chain, structural polymer where the sugar molecules are tightly bonded together into chains and sheets joined by strong beta-glycosidic hydrogen bonds. Lignocelluse is formed by stacking layers of snow-flake-like sugar molecules on top of each other like dragon scales and locking them together with the strong beta bonds to make laminated layers of waterproof armor plating that line the walls of cells in trees and give wood its strength. Hemicellulose is like lignocellulose, only expanded to 3 dimensions, and is as hard as bone or ivory. For yeast fermentation to work, each of these must be broken down into individual sugar molecules, which means all the hydrogen bonds between the sugar molecules must be broken (i.e., hydrolyzed). Starch and its easy alpha bonds are an entirely different proposition than cellulose and the others with their stronger beta bonds and much higher bond-density.

Now to your research.
Syngenta’s “Cellerate” technology is claimed to infuse its GMO Enogen corn kernel with alpha-amylase. Amylase is an enzyme that breaks down starch into sugar. Alpha-amylase specifically breaks down the alpha bonds of starch. It does not operate on the beta bonds of cellulose or hemicellulose. Breaking down cellulose requires a specialized cellulase enzyme such as Cel7A to tear it apart into ribbons and then snip it into individual sugar molecules to make it available for yeast. Breaking down lignocellulose and hemicellulose is best accomplished with high-energy explosive steam and acid processing, and this still leaves the cellulose to be further broken down into individual sugars. None of this is new ground. The paper industry has been working this problem for centuries.

To sum up, your research lends support to the theory that Quad County is processing starch, not cellulose.

As to the EPA and the value of their certification, consider the source. This agency has proven itself over and over again to be a political body where ideology trumps facts and science. This is the same EPA that has been forced to admit by the National Academy of Sciences that their RFS program, specifically designed to reduce GHG emissions, has actually increased both GHG emissions and polluting ozone and particulates emissions compared to the consumption of conventional petroleum fuels. This is the same EPA that has miscalculated the amount of produced cellulosic ethanol by up to six orders of magnitude for 8 years in a row because it has no grasp of the challenging chemistry or energy balance involved. This is the same EPA that mandated the use of MTBE oxygenate in gasoline to reduce carbon monoxide car exhaust, but ruined groundwater in the process, then mandated ethanol as a replacement, which has actually increased CO emissions while still threatening groundwater the same as MTBE. This is the same EPA who perversely considers food crop sugarcane ethanol to be an “advanced biofuel” and subsidizes its import from Brazil into the USA to displace cheaper domestically refined gasoline which is then being exported to South America, undermining US energy independence and energy security and raising the international price of sugar. The is the same EPA which has hypocritically granted E10 ethanol a standing waiver from its own pollution standards for exceeding Reid Vapor Pressure and releasing increased volatile organic compounds that promote smog. This is the same EPA that is in violation of federal law (16 CFR 260.15) for not properly enforcing claims of renewable energy to exclude those fractions created with non-renewable resources and forcing producers to buy RECs before being able to claim the title of “renewable” or be eligible for RINs. This is the same EPA that for years fined petroleum refineries for not blending non-existent cellulosic ethanol into their fuel until it got slapped down by a federal court. This is the same EPA that has approved a laundry list of non-native, invasive, GMO, and nuisance weed species to be cultivated across the USA as biofuels. This is the same EPA that is trying to shut down US coal plants for mercury emissions when it acknowledges that more than half of the mercury that lands on US soil comes from Chinese coal plants. The list or irrationality goes on. The certification of this GMO corn pathway and determination of 60% GHG reduction was likely a paperwork drill based on a questionnaire and perhaps some modeling. Something like this really needs objective verification from chemists on site that measure the actual mass balance of inputs and outputs as well as the process energy flows and sources. EPA’s renewable fuel efforts to date are hurting rather than helping the climate and the environment. Congress really needs to rein them in.

I like your cellulose chemistry depiction, but the chemistry is well known through out the industry. Nobody is going to be able to pull a fast one. I don’t like EPA operations as well, but usually a complaint of them being to heavy handed with compliance and regulatory cost. They would love to comply with your desires to staff up and increase budget. Your saying the division is corrupt and can’t be trusted. Well that is a pay grade above my ability and insight. Both your post and Robert’s posts of ethanol industry trickery of utilizing technology that was discovered decades ago. Well, that’s like impugning modern stove technology because fire was invented long ago. Or saying Nissan Leaf technology is a scam because early 20th century auto manufactures already had a battery car capable of 40 mile propulsion and they did. Your post also utilizes the propaganda trick of singling out a fact, then making bad generalizations. For example EPA had to admit ethanol increases pollution. O.k. pollution does increase, but at a much lower and less harmful rate as compared to plain gasoline. An often quoted MTBE study making the accusation that ethanol is worse. The claim is upon a fuel spill ethanol evaporates quicker and this would infer the environmentally and health harmful component of gasoline benzene would stick around longer. Ok, but ethanol blended fuels have less need and replace more of the bad component, benzene. That’s a good thing and step in the right direction. Ethanol’s attributes have been well known to be much less harmful per fuel spill. Well known to overall decrease GW gas pollution and usage of which will improve air quality. One interesting real life point. Fifty percent of air pollution emitted from just 10% of fleet. These are the high emitters of old vehicles or defective pollution control equipment. Ethanol is extremely beneficial to air quality within this group. Same with the small engines, off road, marine engines that lack good pollution control abilities. The trick often told of old vehicle owners fueling up on E85 before tail pipe emissions inspection. Pass.

“This is the same EPA that has been forced to admit by the National Academy of Sciences that their RFS program, specifically designed to reduce GHG emissions, has actually increased both GHG emissions and polluting ozone and particulates emissions compared to the consumption of conventional petroleum fuels.”

I appreciate what you have to say. You seem to be a very good source in seeking the truth.
In layman terms, can you please explain how ethanol mixed in our conventional fuel actually increases GHG emissions?
The converse of this – is major part of the premise of which the ethanol industry seems to stand on pursuant to their marketing. What the Heck!
Elaborate on this a little – please.

Robert,
Thank you for the question. This comes down to the difference between the common but misleading practice of just counting tailpipe emissions, and the proper accounting of all the emissions of making and consuming a fuel — aka “lifecycle” emissions.

It takes a lot of non-renewable fossil fuel energy to make biofuels. This includes ammonia fertilizer made from natural gas, herbicides and pesticides and designer enzymes made from petroleum feedstock, farm equipment fueled by petroleum, electricity from coal and gas and nuclear plants, coal and natural gas process heat, and hydrotreatment and other upgrading processes using natural gas and petroleum. It also takes a lot of finite, non-renewable minerals that must be mined and refined and shipped such as potash and phosphate imported from Canada and Morocco and Chile. It also requires a huge amount of acreage per unit of energy, and this land must be converted from diverse natural biome to artificial monoculture, usually of non-native or GMO species. Converting land from forest to farm destroys a huge natural carbon sink and also the perpetual carbon appetite that pre-existing natural biome represented. Besides CO2 from burning forests and peat and other land use change, there are more potent GHGs released by agriculture such as methane (34 times more warming than CO2) and nitrous oxide (298 times more warming than CO2). When all these energy inputs and their associated GHG emissions are properly tallied up, most of the biofuel being produced for RFS today releases more GHG than the petroleum fuel lifecycle it is theoretically displacing. This practice of properly counting all lifecyle emissions including those associated with land use change only became the accepted practice about 2008, and it is now formalized in international standards such as PAS 2005 and ISO 14067. The EPA and the National Academy of Sciencies agree that RFS has increased lifecycle GHG emissions to date. Amazingly, the US military continues to ignore indirect land use change GHG emissions in its assessment of biofuels in evaluating their conformance to the Congressional requirement in EISA section 526 that they achieve genuine emissions reductions compared to fossil fuels. This reveals that it is not really concern about the climate that drives their program, but an executive branch political agenda (see Solicitation Number Defense Logistics Agency – Energy. “Sources Sought Notice for Inland/East/Gulf Coast Region – Federal Business Opportunities: Opportunities.” FedBizOpps.gov, June 18, 2014. https://www.fbo.gov/index?s=opportunity&mode=form&id=e806a983245d4bf72dfaffd965f5c7f9&tab=core&_cview=1 ).

But even including the whole lifecycle is not enough; a proper analysis needs to go a step further. We can’t just compare gallons of end product to each other; we need to consider opportunity cost, which is to say we need to compare the ROI in energy and emissions savings between different fuel creation paths. To reduce energy consumption and emissions, we must choose the most energy-efficient path of energy production. The metric that matters here is EROI (energy return on investment), and it is dismal for biofuels. EROI is one of the key topics addressed in the papers I have written, and the upshot is that lower-EROI fuels cannot substitute for higher-EROI fuels. Just like low-ROI investments bring down the overall ROI of an investment portfolio, low-EROI fuels bring down the overall EROI of the US economy. Biofuel production at all phases depends upon a continuous energy transfusion from higher-energy-quality fossil fuels, and this critical dependence upon massive energy subsidies prevents biofuels from truly displacing fossil fuels. The net effect of padding the US energy portfolio with low-EROI energy is that we are actually consuming more crude oil and natural gas to cultivate and process 129 million tons per year of corn into ethanol at an EROI of 1.25:1 than we consume making that 10% of our fuel supply from refined petroleum at an EROI of better than 10:1. The simple irony is that we simply can’t afford to burn all the fossil fuel necessary to make biofuel work.

The EPA does not have to consider ROI or “opportunity cost” or embedded fossil fuel dependence when it spends taxpayer money and consumes our natural resources and sacrifices our environment to feel-good ideology, but American citizens should understand the ground-truth of what is really happening. Biofuels are largely the conversion of hydrocarbons into carbohydrates back into hydrocarbons. This needless churn is wasteful of energy and money, is an affront to the second law of thermodynamics, and is tantamount to trying to achieve perpetual motion in chemistry. It is much more energy-efficient and kind to the climate to let each resource play to its strength by using fossil fuels for fuel and agriculture for food.

The ethanol industry has been heavily reviewed and analyzed with positive ratings for emissions tail pipe to production and the positive production ratings continue to climb. Land use data very blunt instrument per assumptions. Reality, very few forest plowed over for corn. Land Bank acres often abused per assumption of pristine wild land verses farm land in reserve just wasting per weed infestation. Also, satellite data have corn field photosynthesis higher than dense jungle. So, farm field do more for CO2 conversion and do so in non tropic grow zones. Same with comparisons of forest growth. Old forests are carbon neutral as the rotting matter offsets tree growth. Latest soil microbiology of farm fields and root growth have greatly increased carbon rating of farm products. Cellulose tonnage per acre for cellulosic feed stocks put forest growth to shame. The life cycle and well to wheel data all include the inputs you post and ethanol, last I read, enjoyed 7.4x output vs fossil fuel input. The earliest and lowest rating of energy return of 1.3 not always a good way to measure value. For example no cost or value to environment included. California review of last six studies had corn ethanol slightly less than gasoline for petrol input. Crude oil on energy returns slid from historical high of 100:1 to 3:1. Often ethanol opponents count sunshine against ethanol as an energy input and fail to attribute any of the coproducts. Hydro sits at 40:1, but environmentalist claim all possible hydro developed because the grid is not available. Yet they see no problem hooking the grid to remote wind power? The Danes have wind power up to 20:1, but we all know the quality of wind power is way below hydro power, so the high evaluation bogus. Energy in/out calculations another venue to evaluate energy sources, yet business and dollars basically the same evaluation and much more accurate per reality. Note, my gas station has E85 close to $2/gallon and wholesale E85 selling as low as $1.35/gallon.Also, how do EROEI calculations handle the fact that ethanol per ability to increase engine efficiency improves mileage of gasoline? Up to 30%. That’s up to the point where ethanol mileage is equivalent to gasoline. What are the health benefits or environmental benefits measure within energy return? You tabulate any of that cost as well as military need for crude oil? Don’t think ISIS is planning on any small busisness ethanol operations.

I didn’t mean to infer the Enogen corn amylase enzyme was converting cellulose to ethanol. The enzyme does decrease the viscosity of corn powder mix and this was important to the cellulosic side of the process that is propitiatory.

According to the USDA, about 50% of ammonia and 70% of urea N fertilizers used for agriculture in the U.S. are imported. So much for biofuels increasing energy security. We are trading our dependence on foreign oil for an even greater dependence on foreign fertilizers. The RFA always forgets to mention that when they are touting the benefits of renewable fuels. Without cheap natural gas and cheap labor in places like Trinidad and the Ukraine, renewable, American-made ethanol would not be possible.

Well, it’s good to purchase fertilizer from low cost supply. I have friend that works at the largest supplier of fertilizer. It’s dangerous work, but the income stream is ludicrous. He is a long time engineering employee of the firm. His comment upon sudden riches of corn farming. No way would his company let farmers keep all the increase. The U.S.companies appear to have collusion and lack of competition on their side. Also, the regulations keep competition away. Probably good old political powered cronyism. At least international trade can undermine this activity. I have read of a farmer cooperative that is investing in wind turbine technology hydrogen process for fertilizer. Also, the recent Nobel Science prize award for discovery and technology to utilize nitrogen fixing nodules common in legumes to other agricultural plantings. The common practice of following up corn crop with soybean will decrease nitrogen need 30%. Also, the gaining practice of accurate application of the fertilizer improves bottom line cost and environment.

It’s good to purchase everything from low cost suppliers. Now, it’s possible to produce ammonia and urea domestically from renewable biomass. Two U.S. companies that are working to commercialize biomass-to-fertilizer are Syngest (http://www.syngest.com/ ) and BioNitrogen (http://www.bionitrogen.com/ ). Our government thinks it is wise to mandate consumption of high cost ethanol, as a way to force motorists to purchase home-grown, renewable fuels. By the same logic, shouldn’t we mandate consumption of high cost, home-grown, renewable fertilizers? If it’s good for corn farmers to mandate bio-ethanol, why not mandate bio-ammonia and bio-urea? And what do you think would happen to food, feed, and fuel prices if we forced farmers to use American-made, renewable bio-ammonia and bio-urea?

Good points. Same could be said of renewable plastic. Abengoa is selling a soil amendment per their cellulosic process. The bio gas digester bottoms have a proven fertilizer benefit. Municipalities are flirting with technology to produce fertilizer, ethanol, bio gas, or all three. I read once there was enough fertilizer within human urine for entire corn crop. BTW that is a perfect and sterile nitrogen source that goes unused. If your attempting analogy of petrol forced to use ethanol, well petrol is not forced to use ethanol within its production process. The RFS is akin to the CAFE requirements that puts performance standards on suppliers to decrease effect of CO2 emissions. For example if it were not for the CAFE requirements auto companies would be in full swing to produce luxury 4×4 truck behemoths to maximize sales as cost of fuel down. This will swing country to crisis once again if supply chain of oil is disrupted. The CAFE works to keep a steady pace upon auto technology to improve efficiencies. Same with RFS. The regulation stabilizes demand of biofuel to not be disrupted per cost or demand to ensure investment and development of renewable energy as that has been determined to be in best interest of countries future. Cost for corn ethanol not a problem currently as my gas station is close to $2/gallon. Aslo, E85 wholesale is now down as low as $1.35/gal. But, corn ethanol production per RFS is almost maxed out so not many investors building new plants. They are investing in cellulosic process as the RFS has just started to make demands on that fuel source. Much technology and investors lined up for the challenge and promising rewards, but currently getting cold feet per the shell shocked revision of the law thanks to crony capitalism politics.

More to your point, I don’t see a difference except the most of the federal regulation directed to GW or transportation fuel. Remember politics of Bush era demanding he do something on $3/gallon gas as the country was about to implode, (notice now the CIC is not responsible for $4/g fuel and the subject is not broached upon media. Also, flue shots vs Ebola politics where in all the old people where about to die with out adequate flue shot supply vs don’t bother your little head about Ebola missteps per media). My guess the bio fuel fertilizer would be caught up in the GW emission benefits and receive EPA grant for development. If the process is a real win business will go it alone per benefit of trade secrets and protecting property rights. Maybe they would generate a Renewable Fertilizer Supply reg?

Biodiesel has had a similar problem for some years now. Consumers began demanding biodiesel made out of waste stock instead of food stock. Refiners began mixing trace (in theory) amounts of biodiesel made from waste with biodiesel made from food stock and marketing it with varying names claiming it was made from waste but without any labeling of percentage and no validation at all.

This link has more info with EPA redefinition of cellulosic ethanol requirement of 75% cellulose feed stock that Ike Kiefer post refers to. This would enable full cellulosic RIN qualification if it can be proven 60% reduction in GHG emission. If the 75% criteria is not met they prorate to actual content. The bio gas is just another pathway as a bunch other processes. It reads like normal bureaucratic regulatory process to adapt to reality of administrating the law. Your guest post S. Michael Holly suggestion of utilizing feed in tariffs a much simpler approach to supporting alternative energy. I think he was spot on.

EPA just updated EMTS with September data, and D3 cellulosic ethanol RINs have now leapt up to 7.5 million for the month. Three months ago before this rule change, they were ZERO. Since RINs are paid by taxpayer money, EPA should disclose RINs by company, not just the collective count. Taxpaying citizens have a right and their representatives have a responsibility to investigate the specific companies and feedstocks and pathways judged to be genuinely reducing GHGs by the EPA so they can be objectively examined by GAO or CBO using federal laboratories not affiliated with EPA.

You might be simply conflating the two? At this point speculation and not much to worry about as 7.5 million gallons not a large quantity. The four earliest cellulosic commercial processors have been operating in test batch modes and may have received credits for this production? Two of the processors have been in full production for most of September. The production data usually is published just not retroactive, but per summaries. You were all concerned of ethanol’s outdated analysis of energy invested energy out, so you should be elated of cellulosic skyrocket numbers, right? That go up to 80:1, funny but true all the energy cost all ready thrown to corn ethanol side so cellulosic can sit with free energy. It was interesting data that appears when biologist were attempting to evaluate the stover leftovers. How much to leave behind. They discovered, old science not accurate as the bushels per acre and corn plants per acre have increased so much the corn fields were biologically choking on plant matter. The matter was utilizing more nitrogen than plant matter benefit of soil. Also, of big discovery they figured out what gardeners have. That tilling soil is a big no no. That the practice destroys soil micro biology. That nature has always worked best with plant matter placed on surface. Modern farmers had no choice as the stover had to be plowed under to eliminate the large waste pile. This info is a bit revolutionary to farm argonomics as the practice of heavy equipment thundering up and down soil is gaining evidence as a no no as well.. Think of raised bed gardening to understand whats going on and the book and gardening practice labeled as Genesis gardening. This guy was exactly right. So, in the future drones may play a major role in agriculture? How about receiving farming in a box purchase from Amazon where in you can control a groupings of drones from your computer screen to autonomously seed, water, fertilize and harvest even small plots of land. May farmers of the future rely on wind turbine energy to maximize drone fleet refueling? Plant per square foot gardening practices? Suck up bad bugs, water and fertilize individual stalks? I guess talk like this would shake up the older farmers.

“That tilling soil is a big no no. That the practice destroys soil micro biology. That nature has always worked best with plant matter placed on surface”.

Simply put, Forrest – “Soil Microbiology” is one of the largest UNKNOWNS in todays Agriculture. We don’t specifically identify, track and inventory this component of the soil in any meaningful way regarding today’s Ag.

So – I caution anyone from making speculations and broad general statements regarding this very complex soil component as I quoted from you above.

Being involved in this arena for nearly a half century – not only myself, but also the best soil scientists and soil testing labs in the country, admit soil microbiology is relatively a completely uncharted territory, pursuant to any definition of qualifying and quantifying “proper-soil-microbiology-balances”. This being said, we also identify it as a likely new frontier of great importance.

If you have specific data regarding the complexity of this soil component involving a great magnitude of all the various micro-organisms – and their individual soil health influence – please share it – because the very best soil science people admit comprehensive incompetence in this area.

CAUTION:
On broad general statements about conclusions on soil microbiology.

One would think the ancient well researched soil sciences would present no new revelations, but this is not the case and yet another reason that politicians that claim GW is settled science have no understanding of science. For example the Nobel prize for science awarded to novice not trained within the plant or soil science. Per observation and trial the gardener adapted legume mold nitrogen fixing nodules to farm plants. This is expected to have major impact on farm production. Notre Dame plant geneticist accidental blew open another door to soil microbiology by searching for food pathogen within food supply chain. Come to find out soil is loaded with pathogens. A couple square centimeters of soil contain millions of microbes all attempting to make lunch of the other. Jeanne Romero-Severson found a cooperation of an E5 microbe with seeds. The seed apparently grows to include this microbe for no other reason than this microbe fights off other microbe invaders that would destroy the seed once in the soil during the first couple of days whereupon the seed is exceedingly vulnerable until first energy of photosynthesis. The pre-emergence seedling will also uptake more of the microbes from adjacent soil to accomplish increased defenses. The food industry is just finding out the activity of soil science that guarantees healthy plants and food production. She stated the common practice of soil tilling is horrible for healthy soil micro organism as well as soil compaction. Scientist knew relatively little of this hidden world, except to inject fertilizer to spike plant growth. This is why our food supply has within recent history had a devil of a time preventing pathogens (unhealthy soil micro culture). The research of corn stover is widespread i.e. Michigan State among others. The science leads to conclusion of plowing stover under ground is not good and best to place plant matter on top of soil just like nature intended. This will bode well for corn’s GW rating as the plowing practice was energy intensive and the rotting matter usually vented methane gas.

“Per observation and trial the gardener adapted legume mold nitrogen fixing nodules to farm plants. This is expected to have major impact on farm production”.
Forrest was this “gardner’s” name Beijerinck from the Netherlands (1888)? Rhrizobium HAS had a major impact for centuries.

From The Literature:
The first known species of rhizobia, Rhizobium leguminosarum, was identified in 1889, and all further species were initially placed in the Rhizobium genus. However, more advanced methods of analysis have revised this classification, and now there are many in other genera. Beijerinck in the Netherlands was the first to isolate and cultivate a microorganism from the nodules of legumes in 1888. He named it Bacillus radicicola, which is now placed in Bergey’s Manual of Determinative Bacteriology under the genus Rhizobium.

This technology is utilized as seed inoculate to protect from rotting and yes seed legume mold nitrogen. Some of the early evaluations decrease nitrogen requirements by 50% and was reading one that actually returned more nitrogen with dying rootstock than the original corn plant consumed. Common practice of corn farming was to grow soybeans in rotation per the decreased nitrogen requirements, but this is the corn plant accomplishing the same without need of soybean planting. You would do better going to source for your personal research as you post some expertise in this field. As I’ve posted before agriculture is really interesting and has many web sites keeping public up on current technology. Agricultural Colleges have good stuff. Ethanol especially has really kicked the ball down the road to energize farm technology and practices. What is good for ethanol is good for the entire farm operation. The food vs fuel debate within science is pretty lame.

What was initially considered a very harmful soil bacterium…low-and-behold became an essential in the platform for some of the most significant advances ever known in the history of agriculture.
Who’s prepared to say what’s bad and eliminate it? Playing “god” and “all- knowing” in this arena is pretty dangerous!

Salmonella was one such pathogen that was thought picked up from soil. Come to find out much of it in the soil, just active healthy soil is busy killing the pathogen. Scientist are now looking for the good guys and hope to inoculate i.e. bean sprouts to ensure food safety. This science is uncovering our understanding of soil science and it appears very important to plant life. Also, the science is just getting starting, but they know our agricultural practices not very conducive to the all important microbiology. They describe healthy soil as a jungle.

[quote="Ike"]Taxpaying citizens have a right and their representatives have a responsibility to investigate the specific companies and feedstocks and pathways judged to be genuinely reducing GHGs by the EPA so they can be objectively examined by GAO or CBO using federal laboratories not affiliated with EPA.[/quote]

Yes, yes, yesssss. This would be a step toward accountability and away from the existent corporatocracy.

But, I won’t hold my breath, as it’s going to be a long road to such a change.

“Nearly 7.56 million D3 cellulosic biofuel RINs were generated in
September, bringing the total for the first nine months of the year to
more than 11.12 million. According to the EPA, 35,473 of those RINs have
been generated for cellulosic ethanol so far this year, along with
44,168 for cellulosic renewable gasoline, 5.12 million for renewable
compressed natural gas and 5.93 million for renewable liquefied natural
gas. All 11.12 million D3 RINs have been generated by domestic
producers.”

EPA, apparently, not always working behest of ethanol. Their 2014 MOVES emission modeling system is picking up on results of inappropriate fuel sampling. The seriously flawed modeling system distorts emissions of higher ethanol blends of gasoline. The model utilizes elements of CRC testing. The non profit agency supported by API and auto groups that tested blended fuels per Chevron consultant sample choosing. The sampling picks worse case scenario of petrol distillation practices to chose benzene, toluene, xylene and other aromatics to lower vapor pressure of ethanol blends. Then attribute the increase in tail pipe emissions to ethanol. This will probably be peer reviewed separately from petrol interests, before implementation.
It does bring up (in my mind) the practice of vapor pressure control within fuel supply. The VP is adjusted per cold and heat of yearly seasons. This is to maintain good engine starting and keep emissions low. Given, if we had adequate ethanol supplies, it would appear very beneficial to cost and decrease complexity to establish a standard blend of gasoline. Instead of brewing up custom blends to meet VP and seasonal adjustment, better to adjust concentration of ethanol within the mix. Blender pumps could meet the challenge quit easily and not bother the industry with such concerns. Petrol tanks on one side and ethanol on the other. Fuel concentration blended per heat trends. Summer small engine equipment could obtain standard blend to greatly reduce air pollution. Same with winter small engines. Ethanol concentration can increase or decrease VP very accurately. It’s not a complex accomplishment.

I had one question, relating to this comment: “Unfortunately, the EPA, which was created to protect the nation’s land, water, and air from pollution, has become a politicized propaganda instrument for the administration’s biofuels agenda…”

I think the problem is bigger then the current administration, given that most of these cellulosic policies date from the Bush administration. My question is: what is the root of the problem, and how does one go about addressing it? Simply getting the other party in the White House, for example, is clearly a strategy of dubious value.

Is the problem that farm states are “overpresented” in the senate? Or, more deeply, that most Americans believe farm subsidies help the small family farmer, when the bulk of the benefit ends up in the pockets of large agri-corporations like ADM?

Indeed, how does one keep large government departments honest, when there are strong incentives, like those you mention, for them to color the truth somewhat? Notice for example how Treasury shifts the goods included in the basket forming the basis of inflation calculations, so that (voila!) inflation always remains low (double voila! with an extra helping of pat-yourself-on-the-back for all your hard work, and, wait for it, service…).

Please excuse me for butting in here Optimist, but I wanted to get my two cents worth in – (I’m sure Ike’s response to your question will be much more insightful than mine)
My take:
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As long as we have career politicians, going in when they are 30 and leaving when they die, we will continue to have A) policy for career votes – rather than policy for B) the good of the county.
There is no consistent correlation between A & B.
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But many will tell me “GOOD LUCK ON GETTING TERM LIMITS”.
Guess who has to pass that bill. But, can it go on the general ballot some way or another?

Thanks for the suggestion, Robert.
But I’m not sure that is the answer: we have term limits in the CA state legislature, and so far, I fail to see it do us any good. On the contrary: the politicians seem even more clueless, unlikely as that seems. On top of that, they have a weird knack for staying on the state’s budget when their terms are up: they find committee jobs (without term limits), consultancy gigs, etc. And, of course, there is the revolving door that is sure to take care of all the partisan dimwits.

So, IMHO, replacing the scum more frequently just gets you slightly fresher scum of a lower quality…

Well, per your concern, you must be a big supporter of Citizens United decision. Corporations should have a voice as they are nothing more than a group of populace with mutual interest. EPA is the result of modern thinking to cede law making to other unelected divisions of government. This does undermine citizens representation as for example EPA has steadily increased control of business that will always impact citizens. This is probably illegal per Constitutional law, but progressives of both parties are holding their nose as they think it is required for modern society governance. But, this will eventually have to be dealt with.

It is difficult to accomplish your desire as you indicate broad support. Maybe the majority is running roughshod over minority interests of poor international oil corporations? Can’t say you will get very far with that ploy to convince public? It’s hard to convince public of benefits of fossil fuel when they have been deluged with opposite information. Same with the attempts to convince public of horrible alternative energy, especially of low cost ethanol. It starts to sound to public an argument per Groucho Marx, “who are you going to believe? Me or your lying eyes.”

Also note that thanks to EPA the rivers are much cleaner than what they were fifty years ago, and ditto for the air in many cities. Problems with the EPA would be more related to competence and political pressure rather than an inherent hunger for power and legality.

If you want me to discuss the root problem, I will have to go Thomas Paine on you. The issue is that government, which is supposed to be an agency created and funded by the people to do only the specific tasks they give it (i.e., provide external security from invasion and provide internal security and justice with police and courts), has developed its own agenda — and chief among these is for the incumbents to remain in power. Modern socialistic governments are like an evil artificial intelligence that has awakened with its own drive for self-preservation and growth.

A government having its own agenda is only possible when that government has its own secure funding source. Unfortunately, this funding was Unconstitutionally provided by two supremely foolish acts — the creation of the Federal Reserve Board and the improperly ratified 16th Amendment. The first act created a legal cartel between Congress and the banking industry that allows politicians to create money without issuing bonds and thereby without securing the necessary participation and permission of the citizens. The second act allowed Congress to directly tax individual Americans, a right that was restricted to the States in the first 250 words of the Constitution. Both of these acts have crippled the ability of the citizens and the states to rein in their federal government and steer it to do only the things that truly benefit the general welfare. Thus we get political parties and public agencies enacting their own agendas and incurring trillions in debt instead of sticking to the people’s script — i.e., the Constitution.

It is interesting to note that one of the charges made against King George III in the Declaration of Independence was, “He has erected a multitude of New Offices, and sent hither swarms of Officers to harass our people, and eat out their substance.” The proliferation of government agencies is a phenomenon that crosses political parties. It was Nixon who signed the EPA into existence, for example. It only took FDR 11 czars to win WWII, but Obama is now up to 44 — and I don’t think we are winning anything.

The only answer to this Frankenstein we have created is to cut off its food supply. Congress will never do it because they are the ones who get to spend the steaming pile of money that comes to the swamp every year buying more votes to stay in office. It will have to be the state legislatures banded together to force a repeal of the 16th Amendment and the FRB to put the feds back under the leash of the people.

Once we take away the money, we won’t have to worry about term limits. The crooks in coats and ties will go elsewhere to find easier pickings. Like Dillinger targeting banks, they rob the U.S. Treasury because that’s where the money is. We need to pull the money back closer to the taxpayers who can keep line-of-sight on their local politicians for greater responsiveness and accountability.

Can agree with all that. It is tough to keep the wheels on country’s good governance as that requires well educated populace and citizens voting in best interest in country. I remember my public education simplified mechanics of politics/government to citizens that may discover an injustice or problem to run to politicians to apply regulations. That we would eventually live in Shangri La if we apply enough government. Never an honest discourse that government couldn’t solve all social ills or what is the proper use of government. I believe the corruption of countries thinking skills is a direct result of inferior education that has accelerated modern day. You ask a progressive what is priority number one to maintain control, it’s the education system. Unions play pivotal role as they are the diametrically opposed to capitalism and fair competition. Most abide by Karl Marx theory of perfecting society. It is laughable per the guise often exposed of needing Public Education to educate the youth without contamination of bias or prejudice. The open minded marketing only applies to educators whom most worked entire livelihood within Union politics. These Vanguards of the Left, continue to receive maximum praise, recognition, and increase wealth in those states run by like minds. Politics in Michigan are focused to applying maximum resources to public education as that is the foundation of a better future. I think it’s the foundation to corrupt thinking skills of yet another generation.